Deloitte & Touche LLP
Suite 1200
1132 Bishop Street
Honolulu, Hawaii 96813-2870
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www.us.deloitte.com
October 4, 2000
Securities and Exchange Commission
Mail Stop 11-3
450 5th Street, N.W.
Washington, D.C. 20549
Dear Sirs/Madams:
Hosoi Garden Mortuary, Inc. ("Hosoi") requested that we furnish a letter
addressed to the Securities and Exchange Commission stating whether we agree
with the statements made by Hosoi in a draft Form 8-K dated May 10, 2000,
which Hosoi provided to us on August 24, 2000. We informed Hosoi that a
Form 8-K to report a change in the independent auditors of Garden Life
Plan, Ltd. ("GLP") and Garden Life Funeral Plan Trust (the "Trust") did not
appear to be required pursuant to Item 304 of Regulation S-B (S-B 228.304),
because neither GLP nor the Trust is a subsidiary of Hosoi. We also informed
Hosoi that the copy of the draft Form 8-K did not appear to be complete in that
it did not include all referenced attachments. On September 26, 2000, we
received from Hosoi a complete copy of a Current Report on Form 8-K dated
May 10, 2000, which Hosoi informed us was filed with the Securities and
Exchange Commission on August 24, 2000, and re-filed on September 26, 2000
(the "Form 8-K"). Although we believe that a Form 8-K to report a change in the
independent auditors of GLP and the Trust is not required, in response to the
request by Hosoi, we have read the statements made by Hosoi in Item 4 of the
Form 8-K and have the following comments:
. With respect to the paragraph numbered 1,
on May 10, 2000, we informed GLP and the
Trust that we would not accept an
engagement to audit the financial
statements of GLP or the Trust for the
year ending May 31, 2000. We do not agree
that GLP is a subsidiary of Hosoi.
. With respect to the paragraph numbered 2-3,
we were not the principal auditors of the
registrant (Hosoi) and accordingly we have
no comment with respect to the report of
Hosoi's independent auditors on financial
statements of Hosoi. We did not issue
a report on the financial statements of
GLP for the year ended May 31, 1999.
Additionally, we informed GLP that we
believed that the financial statements of
GLP for the year ended May 31, 1998 should be
restated. On October 12, 1999, after we
became aware that Hosoi had included in its
Annual Report on Form 10-KSB for the year
ended May 31, 1999, preliminary drafts of
what purportedly was our reports on the
financial statements of GLP and the Trust
as of and for the years ended May 31, 1998
and 1999, we notified
<PAGE>
Hosoi to cease and desist from using any
preliminary drafts of reports or reports of
Deloitte & Touche LLP not issued or signed
by us in any document.
. With respect to the paragraph numbered 4, we
do not have a basis to agree or disagree with
the statement made, except that we do not
agree that GLP is a subsidiary of Hosoi. We
were not informed that the directors of GLP
made the decision to change independent
auditors for the year ended May 31, 1999.
. With respect to the paragraph numbered 5, we
agree that there are unresolved matters
related to certain accounting principles and
practices of GLP; however, GLP has not
informed us of its position regarding such
matters. The unresolved matters related to
GLP's accounting principles and practices
are (1) the recognition of revenue from
sales of pre-need funeral services contracts
and the related direct incremental selling
costs, and (2) the consolidation of the
accounts of the Trust in GLP's financial
statements. We disagree with Hosoi's
description of our position regarding revenue
recognition and providing a reserve for the
excess of current and expected service cost
over the Funeral Reserve. Our letter to GLP
dated February 17, 2000, which Hosoi filed as
an attachment to the Form 8-K, summarizes
our position with respect to the unresolved
matters related to GLP'S accounting principles
and practices. Such unresolved matters affect
GLP's financial statements for the years ended
May 31, 1998 and 1999. Additionally, we
informed GLP that its obligation to provide
the contracted funeral services should the
funeral services provider (primarily Hosoi)
fail to provide such services should be
disclosed and accounted for in accordance
with Statement of Financial Accounting
Standards No. 5.
Yours truly,
/s/ Deloitte & Touche LLP
c: John Farias, Jr., Garden Life Plan, Ltd.
